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What Would Willie Sutton Say?

In August 2019, I never would have imagined that a banking regulator would be requiring customers to wear masks.  In today's changed world, banking regulators are doing just that.  The California Department of Business Oversight in its August monthly bulletin describes how it is monitoring face-mask compliance at the financial institutions that it regulates:

"The DBO mobilized drive-by spot checks of various branch and storefront locations to verify compliance with the Governor’s order throughout the state. These checks determined whether notices were posted on public facing doors, observed customers entering and exiting the premises, and noted whether a greeter or monitor was at the location restricting access or providing personal protective equipment (PPE)."

I guess Willie Sutton would have to enter a bank without a mask to show that he is there to rob the place and not simply make a deposit. 

I do have one small cavil with the DBO's description, the Governor did not issue an executive order requiring face masks.  The order referenced by the DBO was this guidance issued by the California Department of Public Health.

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About this Author

Keith Paul Bishop, Corporate Transactions Lawyer, finance securities attorney, Allen Matkins Law Firm

Keith Paul Bishop is a partner in Allen Matkins' Corporate and Securities practice group, and works out of the Orange County office. He represents clients in a wide range of corporate transactions, including public and private securities offerings of debt and equity, mergers and acquisitions, proxy contests and tender offers, corporate governance matters and federal and state securities laws (including the Sarbanes-Oxley Act of 2002 and the Dodd-Frank Act), investment adviser, financial services regulation, and California administrative law. He regularly advises clients...